PHMSA Holds Public Meeting To Review UN TDG SCOE Proposals

June 14, 2012

PHMSA HOLDS PUBLIC MEETING TO REVIEW UN TDG SCOE PROPOSALS

This week, the Pipeline and Hazardous Materials Safety Administration (PHMSA) held a public meeting in preparation for the 41st Session of the United Nations Transport of Dangerous Goods Sub-Committee of Experts on the Transport of Dangerous Goods (UN TDG SCOE). The 41st session of the UNSCOE TDG is the third of four meetings scheduled for the 2011-2012 biennium. UNSCOE will consider proposals for the 18th revised edition of the United Nations Recommendation on the Transport of Dangerous Goods Model Regulations, implemented January 1, 2015. The proposals agreed to by the Sub-Committee will be submitted for final consideration and approval in December 2012.

Agenda topics included: explosives and related matters; listing, classification and packing; electric storage systems; Miscellaneous proposals of amendments to the Model Regulations; Electronic data interchange for documentation purposes; Cooperation with the International Atomic Energy Agency; Global harmonization of transport of dangerous goods regulations; Guiding principles for the Model Regulations; and Globally Harmonized System of Classification and Labeling of Chemicals.

The following papers may be found on the United Nations Transport Division Website. For more information regarding the 41st session or proposal, please contact our office.

Paper	Title	Summary	U.S. Position
1	Recommendations for Improvement of Series 8(b) ANE Gap Test and other Gap Tests	Proposes to amend Series 8(b) test procedures by modifying the dimensions and characteristics of permitted steel tubing.	Supported in principle and prepared to address issue within explosives working group.
3	Proposal to change Section 6.2.4 to Permit Alternatives to the Hot Water Bath Test for Small Receptacles Containing Gas – UN 2037 – and Fuel Cell Cartridges Containing Liquefied Flammable Gas	Proposes to harmonize requirements for UN 2037 gas cartridges and UN 3478 fuel cells with those of UN 1950 aerosols and include requirements for alternatives to the water bath test.	Supported in principle, noting format and technical differences in relation to pressure, filling, and leak testing.
4	Special Provisions Requiring Reconsideration	No proposals in this paper. Paper identifies special provisions exempting substances from the Model Regulations based on form/composition.	Amendments under review.
5	Neutron Radiation Detectors	Proposes requirements to permit the transport of Neutron radiation detectors containing non-pressurized BF3 gas provided the detectors meet specific transport constraints.	Not supported as written.
6	T6 Tests for Lithium Cells	Proposes to amend the diameter limit in impact test scope from 20 mm to 18 mm.	Proposal under review.
7	Harmonization with the UN Model Regulations	No proposals in this paper. Requests the ICAO Dangerous Goods Panel revisit and reverse its decision not to apply the provisions of chapter 3.4 to 1.4S articles	Supportive of enhanced collaboration with appropriate modal authorities and interested in stakeholder feedback.
8	Proposal for New UN Number and Special Provision for Heat Transfer Device, Used as Primary Container for Gases Labeled as Dangerous Goods	Proposes specific provisions for dangerous goods in heat pipes.	Not supported as written.
9	Exemptions for Equipment Fixed Permanently on Vehicles and Machines	Proposes amendment to special provision 363.	Proposal under review.
10	Fuel Cell Cartridges/Excepted Quantities	Proposes small fuel cell cartridges (UN 3473, 3476, 3477, 3478, and 3479) be authorized for transport as excepted quantities.	Support inclusion of excepted quantity provisions where article is merely providing a containment function for the dangerous good. Provisions should not be formed on the basis of authorization in checked or carry-on baggage aboard aircraft.
11	Assignment of IBC Packing Instructions to UN 3089	Proposes to amend dangerous goods list for UN 3089, Packing Group III.	Supported.
12	Packing Group UN 3316	Proposes to include two separate entries for UN 3316 in the dangerous goods list. One for packing group II and another for packing group III. The amendments align the UN model regulations with the IMDG code.	Supported.
13	Transport of Explosives, Portable Tank Instructions	Proposes to clarify the header to the tabulated portable tank instructions for T1-T22	Supported.
14	Transport of Explosives, Blasting, Type B and E, in Tanks	Proposes to remove special tank provision TP32 from the entries for Explosives, Blasting, Type B and E, UN 0031 and UN 0032, and replace it with special tank provision TPXX, which excludes the Test 8(d) requirement.	Not supported. Modifying TP32 to exclude the test is not consistent with US safety requirements.
15	Ammonium Nitrate Emulsions – Special Provision 309	Proposes to amend SP309 to include relevant tests of Test Series 8 and to remove the requirement for each substance to be approved by the competent authority.	Proposal under review.
16	IBCs for Transporting UN 3375 Ammonium Nitrate Emulsion, Suspension or Gel	Proposes to eliminate competent authority approval for packagings authorized for UN 3375 and subsequent revisions of Packaging Instructions and Special Packing Provisions.	Supported.
17	Ammonium Nitrate – IBCs	Proposes to include IBC100 Packing Instruction for Ammonium Nitrate, UN0222, as permitted for other explosives, and retain associated Special Packing Provisions B3 and B9 used for Ammonium Nitrate, UN1942, and Explosives Blasting.	Supported with the following amendment: “Such explosives shall not contain nitroglycerine, similar liquid organic nitrates, organic nitro compositions, chlorates, or perchlorates. Metal IBC’s are not authorized.”
18	Ammonium Nitrate Entries – Special Provision 306	Proposes Special Provision SP306 be reworded to make the requirements clearer and avoid the need for additional testing. Eliminates mention of Test Series 1.	Supported.
19	Ammonium Nitrate Description	Proposes to either: 1) amend UN0222 so that it is consistent with Column 2 entry for Ammonium Nitrate, UN1942; or 2) amend UN1942 so that it is consistent with Column 2 entry for Ammonium Nitrate UN0222.	Supported.
20	Classification of Ammonium Nitrate	Proposes to amend the entry for Ammonium Nitrate, UN0222, in Column 2 of the Dangerous Goods List. In the alternative, add Special Provision, SPXXX, to Column 6 of the UN0222 entry.	Supported with the following amendment: replace “ammonium nitrate which has not satisfied Test Series 2” with “ammonium nitrate which gave a positive result in Test Series 2.”
21	Recommendations for Improvement of Series 8(b) ANE Gap Test and other Gap Tests	Proposes to amend 18.5.1.2.1(c) of the 8(b) test procedure to read: “Tubing, steel seamless, with a minimum inner diameter of 66 mm, a minimum wall thickness of 7 mm, and with a length of 280 mm.”	Supported.
22	Changes to Screening Test for Substances that may have Explosive Properties	Proposes to amend 20.3.3.3 of the Manual of Tests and Criteria as follows: “Thermal stability may be estimated using a suitable calorimetric technique such as differential scanning calorimetry or adiabatic calorimetry. For estimating exothermic decomposition energy, a suitable calorimetric technique such as differential scanning calorimetry may be used.”	Supported in principle and invites comments on the impact of removing the adiabetic method. Proposes differential scanning calorimetry shall be used as the suitable calorimetric technique.
23	Proper Shipping Name for Asymmetric Capacitors	Proposes specific provisions for transport of asymmetric capacitors	Proposal under review.
24	Medical Devices or Equipment Containing Infectious Substances	Suggests guidance e developed to clarify intent of exceptions added minimizing packaging standards for such devices or equipment potentially contaminated with or containing infectious substances.	Supports further discussion on implications of recent amendments and working with CDC on a detailed review.
25	Excepted quantities	Provides list of substances forbidden for transport on passenger aircraft but have been assigned an EQ code in the UN recommendations and asks to assign value of E0 for these entries.	Supports alignment of assignments in accordance with provisions of the guiding principles.
26	Proposal to Amend Packing Instructions P602	Proposes glass receptacle be required inside inner packaging provided supplementary packaging is surrounded by cushioning material.	Supports application of 5 L limit to innermost receptacle and allows inner packaging, as defined by the UN Model Regulations, to exceed 5 L limit to accommodate additional supplemental inner packaging.
27	Special Provision 335: Exemption for Small Quantities of Environmentally Hazardous Substances	Proposes to amend existing provisions for dangerous goods packed in excepted quantities to address small quantities of environmentally hazardous substances.	Supportive of providing more appropriate provisions for transport of small quantities of EHS. Not supportive of applying new marking to transport units based on exceeding 1000 package limit.
28	Classification of Desensitized Explosives for the Purposes of Supply and use: Test Results on Industrial Nitrocellulose	Proposes to introduce the German classification system of storage groups for industrial nitrocellulose products by adding the test method for determining the burning rate as a test method for desensitized explosives and introducing a special provision.	Proposal under review.
29	Lithium Batteries: Clarification of P903	Proposes to clarify the intent of P903(2)(a) so the text will read “strong outer packagings, or protective enclosures.”	Supported.
30	Proposed Alternate Flash Composition Test for Fireworks Classification using the Default Table	Proposes adoption of the DDT flash composition test as an alternative to the HSL Flash Composition Test Method.	US Proposal.
31	Used Health Care Devices or Equipment	Proposes removing 1.2 meter drop test for devices or equipment having a mass greater than 12 kg provided the device or equipment is packed in strong outer packaging, in protective enclosures, on pallets or other handling devices.	Not supported as written.
32	Proposals for Amendments to Descriptions of Labels, Placards, Symbols, Markings, and Marks	Proposes to revise limited quantity marking, excepted quantity mark, environmentally hazardous substances mark, orientation arrows, class/division labels, class/division placards, elevated temperature substance mark, IBC and large packaging stacking load symbols, packing instruction marks P650 and P904, fumigation warning mark, and coolant/conditioning unit warning mark.	Supported.
33	Introduction of New Entry for Generators of Ammonia Active Heat or Cartridges	Proposes introduction of new entries in the dangerous goods list to address new technology systems which control the emissions of oxides of nitrogen by the generation of anhydrous ammonia.	Proposal under review.
34	Assignment of Packing Groups to Articles	Proposes to add that “articles assigned to classes 3, 4, 8, and 9 and divisions 5.1 and 6.1 are not assigned packing groups. For packing purposes any requirement for a specific packaging performance level is set out in the applicable packing instruction.”	Supported in principle, as it would reduce the complexity of documentation without compromising safety.
35	Proposal to Amend Description, Proper Shipping Name, and Special Provisions for UN 0503 (Class 1.4G) and UN 3268 (Division 9) by an Entry on “Safety Devices for Vehicles”	Proposes to amend the entry for UN 3268 to address a broader range of safety devices for vehicles. Will result in corresponding amendments to UN 0503.	Supportive of effort to develop proper classification and transport provisions.
36	Proposal for Classification Criteria and Packing Requirements for Gases Absorbed on Solids	Proposes new proper shipping names, special provisions, and packaging instructions for various absorbed gases.	Supported in principle.
37	New Special Provision and Packing Instruction for Damaged or Defective Lithium Batteries	Proposes to add a Special Provision and two new Packing Instructions to Model Regulations for transporting damaged or defective lithium cells and batteries.	Proposal under review.
38	Special Provision and Packing Instructions for Waste Lithium Batteries	Proposes to include a new Special Provision and Packing Instructions P903a and P903b.	Proposal under review.
39	Large Packaging Packing Instruction for Lithium Batteries	Proposes revised large packaging instructions for lithium batteries.	Supported.
41	Packing Instructions P116, P131, and P137	Proposes adding “bags 5H2 and 5H3” for packing instruction P116 and “boxes – plastics, solid (4H2)” for packing instructions P131 and P137.	Supported.
42	Amendments to the Guiding Principles – Packagings	Proposes revisions to packaging instructions section of the guiding principles based on input from previous meetings.	Supported.
43	Guiding Principles at Part 4.3C – Tank Instruction Assignments for UN Portable Tanks	Proposes text of Part 4.3C of the guiding principles provide guidance on changing assignment of one portable tank instruction to another for particular substances.	Not supported as written, as it introduces specific criteria that could adversely impact ability to make appropriate safety-related amendments to portable tank assignments.
44	Fire Extinguishers: Assignment to UN 1044 and Packaging	Invites comment regarding problems with classification, packing, and transport of various types or portable or movable fire extinguishers as well as cylinders installed as replacement parts in local fire extinguishing installations.	Paper contains no proposals.
45	Proposal for a New UN Number and Special Provision for New Confetti-Shooters	Proposes a new table entry for “articles containing small gas receptacles with non-flammable gas, intended to function as confetti-shooters” and proposes specific packaging and testing requirements.	Supportive in principle; however, concerned that proposal singles out a specific application rather than providing broader approach.
47	Electronic Data Identification	Proposes adoption of a system of key identifiers for use alongside Dangerous Goods List in Chapter 3.2 of the Model Regulations.	Opposes effort to introduce primary key identifier system to UN Model Regulations.
48	Asbestos	Proposes to revise proper shipping names for asbestos to indicate chrysotile and amphibole and revisions to 2.9.2.	Not supported.
49	Amendments to the Classification Flow Chart/Decision Logic for Self-Reactive Substances and Organic Peroxides	Proposes amendment to classification flow chart for organic peroxides and self-reactive substances.	Supported.
50	Classification of Self-Reactive Substances	Questions whether: 1) substances that polymerize should be classified as self-reactive substances (SRS); 2) test methods for SRS are appropriate; 3) limited testing suffices for substances that exothermically self-react by polymerization; 4) it is necessary for polymerizing substances to be classified by competent authority or should classification by consignor continue to be permitted; and 5) proper shipping name should be assigned is a substance poses no hazard other than polymerization.	Supports consideration of issues.
51	Pyrotechnic Compositions Subjected to the HSL Flash Composition Test and Proposed US Modified DDT Test	Proposes Working Group on Explosives consider introduction of Modified US DDT Flash composition test as new Appendix 8 to the Manual of Tests and Criteria.	Not supported. Believes Modified DDT Flash Composition Test in Working Paper 30 should be adopted and pyrotechnics industry should have freedom to choose between one of the two methods, rather than running both.
52	Transition Provisions for ISO Standards – Section 6.2.2	Proposes text for guiding principles be replaced by updated standards, introduces parts of ISO 9809, and provides amendments that would appear in section 6.2.2 if proposal adopted.	Proposal under review.
53	Packing Group UN 3316	Proposes amendments to 5.5.3 to clarify which requirements apply to cargo transport units containing packages with cooling/conditioning substances and which apply to cargo transport units containing unpackaged cooling/conditioning substances.	Proposal under review.
54	Special Provision 172	Proposes that wording of special provision 172 be revised to make subsidiary risk consistent with basic sequence of dangerous goods description in 5.4.1.4.1(a)-(d).	Supported.
55	Proof of Concept on Use of Electronic Data Transmission in lieu of Paper Dangerous Goods Transport Document	Proposes to validate that shipments of dangerous goods can move through air transport without needing a paper dangerous goods transport document.	Supports electronic transmission of hazardous materials data and looks forward to proof of concept results.
56	Substances and mixtures with Explosive Properties Exempted from Explosive Classification	Presents revised notes regarding proposal to introduce a note in the GHS for substances and mixtures with explosive properties which are exempted from classification as explosives.	US Proposal.
57	Recommendations for Clarification related to the Test Series 6(c) Bonfire Test	Proposes to clarify the number and orientation of video cameras used for the test and clarify requirements to successfully pass the test.	US Proposal.